Your GDPR Rights

1

Right to be Informed

You have the right to know what personal data we collect, why we collect it, and how we use it.

• • What data we collect (browser info, location, preferences, email)
• • Why we collect it (improve service, personalization, analytics)
• • Who we share it with (Google services, analytics providers)
• • How long we keep it (varies by data type, up to 26 months for analytics)

How we fulfill this: Our detailed Privacy Policy explains all data practices

2

Right of Access

You can request a copy of all the personal data we hold about you.

• • Request includes all data categories we have about you
• • Provided in a commonly used, machine-readable format
• • Includes information about data sources and sharing
• • Free of charge for the first request

How to request: Email legal@bugle.ie with "Data Access Request" in the subject

3

Right to Rectification

You can ask us to correct any personal data that is inaccurate or incomplete.

• • Correct factual errors in your personal information
• • Complete incomplete data
• • Update outdated information
• • We'll notify third parties of corrections where required

How to request: Email legal@bugle.ie with details of the incorrect information

4

Right to Erasure ("Right to be Forgotten")

You can request that we delete your personal data in certain circumstances.

How to request: Email legal@bugle.ie with "Deletion Request" and specify what you want deleted

5

Right to Restrict Processing

You can ask us to temporarily stop processing your data in certain situations.

• • When you contest the accuracy of data (while we verify)
• • When processing is unlawful but you don't want deletion
• • When we no longer need data but you need it for legal claims
• • While awaiting outcome of objection to processing

Effect: We can store the data but not actively use it without your consent

6

Right to Data Portability

You can request your data in a portable format and have it transferred to another service.

• • Applies to data you provided and we process automatically
• • Based on consent or contract performance
• • Provided in structured, commonly used format (JSON, CSV)
• • Can request direct transfer to another organization (where technically feasible)

Examples: Your account preferences, newsletter subscriptions, comment history

7

Right to Object

You can object to certain types of processing of your personal data.

8

Rights Related to Automated Decision Making

You have rights regarding automated decision-making and profiling that significantly affects you.

• • Right not to be subject to purely automated decisions
• • Right to human intervention in automated decisions
• • Right to explanation of automated decision logic
• • Right to challenge automated decisions

Note: We currently do not engage in automated decision-making that significantly affects users

Making a Request

Information to Include

To help us process your request quickly, please include:

• • Clear subject line indicating the type of request
• • Your full name and email address associated with your account
• • Specific details about what data or action you're requesting
• • Any relevant dates or time periods
• • Preferred format for data delivery (if applicable)

Identity Verification

To protect your privacy, we may need to verify your identity before fulfilling requests:

• • Government-issued photo ID (passport, driving license, national ID)
• • Proof of address (if requesting data associated with a specific location)
• • Additional verification for sensitive requests
• • We delete verification documents after processing your request

When We May Refuse or Delay

In rare circumstances, we may refuse or delay a request:

Important: We'll always explain our reasoning and inform you of your right to complain

Journalism and Freedom of Expression

As a news publication, some of your rights may be balanced against:

• • Freedom of expression and information
• • Journalistic purposes and editorial independence
• • Public interest in access to information
• • Historical and archival value of published content

Example: Comments on published articles may be retained for context and public interest, even if you request deletion

Deceased Persons

GDPR rights generally don't apply to deceased persons, but we recognize:

• • Family members may have legitimate interests
• • Estate representatives may make certain requests
• • We'll consider requests on a case-by-case basis
• • Legal documentation may be required

Minors and Children

Children have the same GDPR rights as adults, with special protections:

• • Parents/guardians can exercise rights for children under 16
• • We take extra care with children's data
• • Enhanced right to erasure for data collected as a child
• • Clear, age-appropriate explanations provided

Third-Party Data

When exercising rights affects others' data:

• • We'll redact or anonymize others' personal information
• • Some requests may not be possible if they harm others' rights
• • We'll explain any limitations and offer alternatives
• • Joint controllers (like Google) may need to be contacted separately

Internal Appeals Process

If you're not satisfied with our response to your GDPR request:

1. Contact us at legal@bugle.ie within 30 days explaining your concerns
2. We'll conduct an internal review within 21 days
3. A senior team member not involved in the original decision will review
4. You'll receive a detailed explanation of our final position

Data Protection Commission (DPC)

You have the right to lodge a complaint with Ireland's Data Protection Commission if you believe we haven't handled your personal data properly or haven't responded appropriately to your rights request.

Other EU Supervisory Authorities

If you're resident in another EU country, you may also complain to your local supervisory authority:

• • You can choose to complain in Ireland (where we're based) or your home country
• • Your local authority will coordinate with the Irish DPC if needed
• • Find your local supervisory authority

Judicial Remedies

You also have the right to seek judicial remedies through the Irish courts if you believe your GDPR rights have been infringed. You may be entitled to compensation for material or non-material damages resulting from GDPR violations.